14 Mar Request To Decide On Eviction With The Cancellation Of The Appeal
….. MAGISTRATE’S COURT JUDGE
PLAINTIFF :
TC IDENTIFICATION NUMBER :
ADDRESS :
Deputy :
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT :
Address :
Subject: our petition includes our request to decide the eviction with the cancellation of the appeal.
INSTRUCTIONS :
1 -) the tenant … … has been living in an apartment located at the street address … …of the province, …district, …owned by our client … … since the date of the oral lease agreement between the parties. The reason that there is no written contract between our client and the tenant is due to the fact that the tenant has known his family for many years.
2 -) The Tenant …. after failing to pay rent for a month in a row, our client was warned by means of a verbal and notarized warning (Annex 1) that he did not pay … the Executive Director …/…. E. a numbered file with unpaid …-initialized followed by prompt payment of rent and eviction TL (Appendix 2) and the lessee to …/…/… on the date the payment order sent within the legal period following the outcome of the appeal and the appeal of the tenant stopped.
3 -) the tenant … … in his objections, he repeatedly went to our client’s house to pay the rent and called him on the phone, but he could not reach him; in the end, he claimed that he paid the rent to our client’s daughter, but they repeatedly faced and spoke to our client in the months without payment. If your court deems it appropriate, it will be clarified by the statements that our witnesses, whose names and addresses are written in the witness list (Annex 3), will give in relation to the matter. And our client’s claim that he paid his daughter is baseless. Because our client’s daughter … He is a student at the university and only returns to his family during the summer holidays, and it is not possible that the tenant paid him.
4 -) for the reasons explained above, it is necessary to apply to your court to ensure eviction with the cancellation of the tenant’s appeal.
Legal reasons: 2004 p. K. m. 269, 269 / b; 6100 S. K. m. 1, 4, 5, 6.
Legal evidence: 1 -) … … dated … / … / … of the notary public and … numbered
references,
2 -) …Executive Directorate …/ … E. Numbered tracking file,
3 -) names and addresses of witnesses and the subjects they will testify
shows the witness list.
Conclusion and request : for the reasons explained above, we respectfully request on behalf of our client that the tenant’s objections to the Non-in-place payment order be removed and that the tenant’s eviction, trial costs and attorney fees be charged to the other party. …/…/…
Annexes: 1 -) … … notice of the Notary Public … / … / … dated and … daily,
2 -) …Executive Directorate …/ … E. Numbered tracking file,
3 -) A list of witnesses that shows the names and addresses of witnesses and the topics they will testify,
4 -) one sample of approved power of attorney.
Acting Plaintiff
Lawyer
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